Action Plan Submitted: 15th February 2019

A Response to: A thematic inspection of work with men convicted of sexual

offences

Report Published: 24 January 2019

INTRODUCTION

Her Majesty’s Inspectorate of Probation is the independent inspector of youth offending and probation services in England and Wales. It

reports on the effectiveness of probation and youth offending service work with adults and children.

In response to the report, HMPPS/MoJ are required to draft a robust and timely action plan to address the recommendations. The action plan

confirms whether recommendations are agreed, partly agreed or not agreed (see categorisations below). Where a recommendation is agreed or

partly agreed, the action plan provides specific steps and actions to address these. Actions are clear, measurable, achievable and relevant with

the owner and timescale of each step clearly identified. Action plans are published on the HMI Probation website. Progress against the

implementation and delivery of the action plans will be monitored by HMPPS/MoJ and reviewed annually by HMI Probation.

Term Definition Additional comment Agreed All of the recommendation is agreed

with, can be achieved and is affordable. The response should clearly explain how the recommendation will be achieved along with timescales. Actions should be as SMART (Specific, Measurable, Achievable, Realistic and Time-bound) as possible. Actions should be specific enough to be tracked for progress.

Partly Agreed

Only part of the recommendation is agreed with, is achievable, affordable and will be implemented. This might be because we cannot implement the whole recommendation because of commissioning, policy, operational or affordability reasons.

The response must state clearly which part of the recommendation will be implemented along with SMART actions and tracked for progress. There must be an explanation of why we cannot fully agree the recommendation - this must state clearly whether this is due to commissioning, policy, operational or affordability reasons.

Not Agreed The recommendation is not agreed and will not be implemented. This might be because of commissioning, policy, operational or affordability reasons.

The response must clearly state the reasons why we have chosen this option. There must be an explanation of why we cannot agree the recommendation - this must state clearly whether this is due to commissioning, policy, operational or affordability reasons.

ACTION PLAN: A thematic inspection of work with men convicted of sexual offences

1.

Rec

No

2.

Recommendation

3.

Agreed/

Partly Agreed/

Not Agreed

4.

Response

Action Taken/Planned

5.

Responsible Owner

(including named

individuals and

their functional role

or department)

6.

Target Date

1 HM Prison and Probation

Service should ensure

that for both custody

and community cases:

Staff are provided with a

clear approach to working

with those convicted of

sexual offences

Agreed The Sex Offending Management Board (SOMB) meets at least quarterly and is responsible for ensuring a strategic and coherent HMPPS approach to management of men and women convicted of sexual offences. The Sex Offending National Reference Group (focused on managing sex offenders in the community) and the recently instigated Sex Offending Forum (focused on sex offenders in custody) both feed into this Board. HMPPS will produce a framework, articulating the priorities of the SOMB; describing the principles which underpin our work with those convicted of sexual offences and providing an evidence informed rationale focussed on identifying the priority issues for service implementation. In addition, a dedicated post to support the Deputy Director for Equalities, Interventions and Operational Practice Group has been created to coordinate the work undertaken in HMPPS on the management of those who have committed sexual offences. The Director General (DG) for Probation and Wales will hold ultimate responsibility for oversight of delivery of the above framework and this Action Plan. Both will be delivered through the Sex Offending Management Board, which will now be chaired by a Director. The Chief Probation Officer will also attend the Board A range of training and supporting materials are being developed to enable clarity about working with sex offenders. This includes:

• ‘My Learning’ (training database) has been launched by HMPPS to provide staff with easy access to all training, including a number of available events in relation to working with those who have committed sexual offences. This database also provides staff and managers with an accurate record of the training completed.

• A revised joint police and probation training package will improve the quality of Active Risk Management System (ARMS) assessments, ensuring that staff have a clear understanding of what constitutes a quality assessment. ARMS will be appropriately prioritised and performance monitored through analysis of Management Information. We will pilot a Quality Assurance tool and include guidance on how to

Head of Equalities, Interventions and Operational Practice Group DG for Probation and Wales; Director for Safety and Rehabilitation

Deputy Director,

Effective Probation

Practice

Head of Public

Protection Group and

Deputy Director,

Effective Probation

Practice

Completed July 2019 Completed December 2019

improve case recording. We are also exploring whether we can make use of ARMS assessments earlier in an offender’s sentence, including the potential to do so in custody.

• A Model for Operational Delivery for those convicted of sexual offences has been developed to support prison establishments in working with their population. This toolkit brings together a comprehensive analysis of the latest evidence, supports successful delivery and acts as a resource which Governors can use to meet the needs of prisoners. This is an iterative set of material which will be promoted to custodial sites. This will be subject to regular review and amended as appropriate to ensure that the latest evidence is used and the changing needs of the prison population are met.

• We will continue to provide staff training and delivery in prison establishments offering relevant accredited Offending Behaviour Programmes (OBPs), to enable staff to understand how to work with those convicted of sexual offences. We will also provide training to the wider staff group, to ensure an understanding of the programme content and aims.

• The NPS has instigated national conferences to communicate a clear approach to working with those convicted of sexual offences. These conferences aim to improve awareness, confidence, theoretical understanding and forward-thinking approaches. Three conferences were delivered in 2018 with a fourth planned in early 2019. It has been agreed that further similar conferences will take place in 2019/20.

• The NPS has launched ‘7-minute briefings’ to condense key information, communicate strategic approaches and provide learning to staff (including to cover required approaches to working with those who have committed sexual offences). This includes both community and custodial programmes and information. To support this, ‘bitesize’ videos will be piloted with NPS Newly Qualified Officers in March 2019 and rolled out to all NPS staff in line with learning from this pilot. Work to provide access for prison staff is underway.

• New Me MOT training (a toolkit of exercises developed in line with empirically supported effective characteristics of supervision) is available to both custody and community staff. A programme to ensure widespread delivery in the NPS will be rolled out over the next two years, commencing with all frontline staff in North East Division to be trained by April 2019.

Head of Reconfiguration Head of Psychological Services

Deputy Director, Effective Probation Practice Deputy Director, Effective Probation Practice/Head of Psychology Services Head of Interventions Service

March 2020

Completed. April 2019 and April 2020 September 2019 February 2021

2 There are regular and

comprehensive national

analyses of offending-

related risks and needs of

Agreed HMPPS recognises the need for a comprehensive national analysis of

offending related risks and needs of those convicted of sexual offences. The

SOMB will drive improved coherence to the analysis of the cohort, with plans

for delivery in custody and the community.

Head of Equalities,

Interventions and

Operational Practice

Group

November 2019

those convicted of sexual

offences

Delivery plans for all accredited programmes are implemented according to the

risk and need of the population and of individuals. The 2019/ 20 Delivery Plan

will be developed by May 2019 and reviewed annually thereafter.

Establishments will continue to analyse the risk and needs of their population,

to ensure appropriate case management and that prisoners are directed to

available interventions as appropriate.

The NPS Performance and Knowledge Management team are exploring the

most efficient means by which to gather further meaningful data. Criminogenic

need and risk data will be obtained via Offender Assessment System (OASys)

National Reporting (ONR) for those whose Index Offence is coded as a sexual

offence.

Head of Psychology

HMPPS and Head of

Intervention Services

HMPPS

Head of Performance

and Knowledge

Management, NPS

May 2019

February 2019

3 Promote closer working

between CRCs, prison

staff and the NPS so that

there is continuity of

resettlement support,

effective public protection

and oversight throughout

the sentence

Agreed Under the Offender Management in Custody (OMiC) specification, the Prison

Offender Manager (POM) will ensure effective coordination of the sentence

during the custodial stage. For registered sex offenders, the POM will support

joint working, information sharing and transition to a Community Offender

Manager (COM) prior to release and NPS supervision. The COM will take

responsibility for resettlement and public protection arrangements in the last

months leading up to release.

The contracts with Community Rehabilitation Companies (CRCs) provide for

through the gate (TTG) services, even where a prisoner does not reside in a

designated resettlement prison prior to release. We are, though, aware the

performance of the probation system, including TTG resettlement services for

prisoners leaving custody, is in need of improvement. Discussions with

CRC providers have taken place and an enhanced TTG offer is currently being

mobilised to increase the level of service by 1 April 2019. This applies to all

resettlement prisons as well as the range of provision available to those being

discharged from sex offender and non-resettlement prisons, via CRC rate

cards. The National Probation Service, CRCs and prisons are working

together to improve the services available. HMPPS will collect data to track

prisoners’ accommodation and employment on release. This data will be used

to measure and drive up the performance of both prisons and probation

services, to address obstacles and to provide incentives for improved joint

working.

Capacity plans in relation to those who have committed sexual offences are built

into the Prison Estate Transformation Programme (PETP)’s new build and

reconfiguration work, including removing barriers to improve flows to

Executive Director,

Safety and

Rehabilitation

Deputy Director,

CRC Contract

Management

Head of Prison

Reconfiguration

Project

December 2019

April 2019

March 2022

resettlement prisons. The custodial Sex Offending Forum will provide feedback

to the SOMB to understand the needs of staff in prisons due to receive an

increase in numbers of prisoners who have committed sexual offences.

The number of available Approved Premises places will be increased by 230

over the next two years. NPS will work with Local Authorities to help them

ensure that, wherever possible, sex offenders are released to stable, risk

assessed accommodation on release from custody and/or following a period at

an Approved Premises. Temporary hotels will only be used when all other

alternatives are exhausted, will be fully risk assessed (by Police and NPS) and

will require the approval of the Chief Probation Officer or Director General for

Probation.

Chief Probation Officer

April 2021

4 Provide evidence informed

interventions for offenders

whose needs are not met

by accredited programmes

Agreed HMPPS seeks to identify the most appropriate approach in line with the latest

research for every offender. Frequently this may be to provide support to build

strengths (e.g. in relation to education, accommodation and employment) to

enable desistance. The Maps for Change Toolkit provides a resource to

structure supervision with men convicted of sexual offences in the community,

to promote evidence informed desistance factors and engagement. Maps for

Change has been re-written and is now linked specifically to Active Risk

Management System (ARMS) items, changes due for release in early 2019.

HMPPS will review the current use of Maps for Change, to determine whether

custodial delivery would be desirable.

Specialist units are available or under development in key custodial

establishments, to address the needs of complex individuals who are not

progressing in their sentence, including lack of progress with Accredited

interventions. This includes Personality Disorder (PD) units and counselling

psychology provision. This provision will be subject to ongoing review.

Head of Equalities,

Interventions and

Operational Practice

Group

and Deputy Director,

Effective Probation

Practice

Head of

Psychological

Services

April 2019

May 2019

5 The workforce is equipped

to identify, assess and

deliver appropriate

interventions to manage

the risk of harm presented

by those convicted of

sexual offences

Agreed Under the OMiC specification, all registered Sex Offenders will be subject to

Offender Management by a suitably qualified member of staff throughout their

sentence. We will ensure that they receive appropriate training to enable

effective supervision.

The available training for HMPPS staff is being updated and will ensure that

the workforce is equipped to engage those convicted of sexual offences and

manage the risk of harm that they present. This includes training opportunities

for Keyworkers and Prison Offender Managers. Training is also being

developed for Newly Qualified and experienced NPS Officers for release in

Executive Director,

Safety and

Rehabilitation

Deputy Director,

Effective Probation

Practice and Head of

Psychology

December 2019

November 2019

late 2019. NPS will pilot a face to face workshop for Offender Managers in

relation to the risk assessment of online sex offenders in March 2019 and a

further workshop to improve staff understanding of the role of legal

pornography in sexual and violent offending commencing in April 2019.

6 IT systems are improved

to enhance joint working

arrangements and to be

available to relevant staff

in both custody and the

community.

Agreed Case Management systems have been updated and improved to increase the

technical capacity for joint working arrangements across custody and the

community as follows:

• nDelius (Community Case Management System) can be accessed by

staff in custody, including through the quantum system used by

custodial staff.

• Data sharing capability has been developed between pNomis (Prison

Case Management System) and nDelius. Key information (including

Case Notes relating to contact with Offender Supervisor or Offender

Manager) entered on pNomis are automatically transferred to

nDelius.

All Offender Managers and some administrative staff in Offender Management

will be vetted, trained and given access to ViSOR (information system used by

Police and HMPPS in relation to Violent or Sex Offender Registered

individuals subject to Multi Agency Public Protection Arrangements

arrangements). Offender Managers will log in daily to check for

information/intelligence, and before each contact with a relevant Service User,

which will be audited by management. To support improved operational use of

ViSOR across the prison estate HMPPS will implement updated mandatory

training in 2019.

Interventions Manager is an IT system developed to support delivery of

interventions (including, but not limited to accredited programmes), bringing

together the interventions relevant for an individual to assist in the planning,

reviewing and sequencing of delivery. It is currently used in the community

and use in custody has been piloted at HMP Berwyn, as a means of better

integrating interventions. The outcomes will be reviewed to determine further

investment.

Deputy Director,

HMPPS Digital &

Technology

Head of Public

Protection Group

Head of

Psychological

Services and Head of

Interventions

Services

Completed

March 2020

September 2019

7 NPS divisions and HM

Prison Service should:

Agreed Under the OMiC specification, all registered Sex Offenders will be subject to

Offender Management by a suitably qualified member of staff throughout their

sentence.

Executive Director,

Safety and

Rehabilitation

December 2019

Improve the integration of

assessment tools and the

quality of assessments

and plans to ensure that

the public, particularly

children and actual and

potential victims, are

protected.

In October 2018 a revised version of the Assessment Quality Assurance

(AQA) tool was introduced, focussing on the quality of the core elements of

NPS work: risk assessment, risk management and sentence planning. This

includes measures to assure and improve the quality of key assessments and

plans within OASys. The impact on quality is being evaluated, and will be

available in February 2019.

HMPPS will launch a revised joint police and probation training package, to

improve the quality of Active Risk Management System (ARMS) assessments.

The QA, Refresher and Assessor training packages will ensure that staff have

a clear understanding of what constitutes a quality ARMS assessment.

NPS will set up a mechanism for collecting Management Information on ARMS

completion, put in place a performance management process and will issue

guidance on the prioritisation of ARMS where there are staff shortages. The

National ARMS team will provide further information on the strengths and

weaknesses of ARMS, and therefore inform further practice development

across HMPPS.

Psychologists take account of available risk assessments when using

additional specialist tools with those convicted of sexual offences, and are

trained in new approaches as appropriate.

NPS will strengthen risk management planning, including by ensuring a more

coordinated approach to Home Visits with the police. NPS will revise guidance

in relation to Home Visits, to set out more clearly the circumstances in which

home visits are required, in particular, with respect to child safeguarding.

Management Information will be used to monitor the use of Home Visits in

appropriate cases.

To ensure that polygraph testing can be used to strengthen Risk Management

Plans where necessary, NPS have increased the size of the national

polygraph team, and given instructions that will ensure that priority is given to

higher risk cases.

Deputy Director,

Effective Probation

Practice

Head of Public

Protection Group

Deputy Director,

Effective Probation

Practice

Head of

Psychological

Services

Deputy Director,

Effective Probation

Practice

Head of Public

Protection Group

February 2019

February 2019

December 2019

Completed

November 2019

Completed

8 Ensure that those

allocated to work with

sexual offenders are

offered the appropriate

level of professional and

Agreed PAM Assist (an Employee Assistance Programme EAP and Wellbeing

Service) offers Structured Professional Support for HMPPS staff (via line

manager referral) that manage predominately high risk and complex

caseloads. A new electronic referral process is being rolled out nationally to

improve access and HMPPS are working with PAM Assist to ensure the

National Lead,

Occupational Health

& EAP, HMPPS and

Probation Divisional

April 2019

emotional support to deal

with the complex, often

difficult, nature of their

caseloads

services on offer meet the demands of our staff. Confidential counselling is

available via the Employee Assistance Programme, which can be accessed

through self-referral. Training workshops related to building resilience and

identifying enhanced coping strategies are available and bespoke training

days can be arranged as required; discussions are underway as to a specific

offer for staff working with those convicted of sexual offences.

In addition, the following professional and emotional support will be available

to HMPPS staff, depending on their role and specific needs;

• A counselling service is available to those facilitating high intensity

interventions (including programmes for those convicted of sexual

offences) and eligibility has been broadened to include other staff

who may work with or be exposed to difficult content or material.

• Regular support from a Line Manager (e.g. Structured Supervision for

NPS staff, Psychology staff and other specialists). NPS will

implement a Supervisory and Line Management Meetings Framework

(SLMMF) from April 2019.

• Access to mentoring schemes or peer supervision (e.g. NPS and

psychology pilots are underway).

• Peer support (e.g. Virtual Networks will be launched in 2019 to

network NPS staff more appropriately to discuss effective practice in

working with those that have committed sexual offences).

• Training (e.g. NPS will launch dedicated training for Newly Qualified

Officers to support their work with those convicted of sexual offences.

This can be accessed by all NPS staff, and has a core focus on

resilience and supporting staff in the emotional impact of managing

those who have committed a sexual offence).

• Bespoke support (e.g. a briefing to help address concerns around

Serious Further Offences and build understanding and resilience will

be available to all managers in early 2019).

• POMs and COMs will have access to psychologically informed

consultancy in relation to cases screened into the Offender

Personality Disorder (OPD) pathway programme. In addition to

providing direct assistance in managing these complex cases, this

aims to build capacity and skills in OMs for future cases.

Director for Business

Strategy & Change

Deputy Director,

Effective Probation

Practice and Head of

Psychological

Services

September 2019

9 Ensure that MAPPA level

setting is consistent,

clearly communicated

Agreed Multi Agency Public Protection Arrangements (MAPPA) Senior Management

Boards (SMBs) are independent bodies and the statutory requirement to

manage the risks presented by those with sexual and violent index offences

Head of Public

Protection Group

September 2019

across the responsible

authorities, and

underpinned by robust

assessment and regular

reviews

rests with them. The national MAPPA Team will review the MAPPA Guidance

(setting out the framework for level setting, communication across the

responsible authorities, the assessment process and regular reviews). Clear

guidance on minimum requirements for single agency management and

review of Level One cases will be produced.

MAPPA Guidance in relation to Custody has recently been updated, clearly

setting out HMPS’s responsibilities in relation to MAPPA. A new escalation

procedure has been introduced for occasions when prisons are not informed of

MAPPA levels. HMPPS will review the effectiveness of this process by

September 2019.

Head of Public

Protection Group

September 2019

10 Ensure that accredited

programmes are delivered

in all appropriate cases

Agreed HMPPS’s new suite of programmes is consistent with the latest evidence and

has the assurance of accreditation by the Correctional Services Advice and

Accreditation Panel (CSAAP). Programmes to address sexual offending within

our New Delivery Model (NDM, November 2017) pay attention to the individual

needs of each participant; place emphasis on the Risk, Need and Responsivity

model of rehabilitation and adopt a strengths-based, future focussed approach

in order to instil hope for a non-offending future. Focus is placed on the

Dynamic Risk Factors which contributed to offending (Positive Relationships;

Managing Life’s Problems; Sense of Purpose; Healthy Sexual Interests and

Healthy Thinking). HMPPS will review the demand for these programmes in

comparison with the volume and location of those we provide, both in the

community and in custody, to improve the available data and support the

prompt allocation of eligible sex offenders onto programmes.

Prioritisation of the provision of programmes for those that have committed

sexual offences is implemented using assessments of risk and need. National

data and local needs assessments will be used to improve the understanding

of the risks/needs of the population. Planning will ensure that programme

availability is aligned with these assessments, taking account of eligibility,

readiness and resource constraints. Planning for 2019/20 has commenced.

A working group is reviewing system improvements to the individual

assessment process to identify those suitable for accredited programmes.

Head of

Psychological

Services,

Deputy Director,

Effective Probation

Practice

Head of

Psychological

Services

Head of

Psychological

Services and Head of

Interventions

Services

Head of

Psychological

December 2019

July 2019

July 2019

Accredited Programmes for people with learning disabilities and challenges

have been developed. Work to embed these programmes within custody and

in the community is ongoing.

Services, Deputy

Director, Effective

Probation Practice

Completed

11 Train staff to deliver

individual work

programmes for use with

sexual offenders who are

not subject to an

accredited sexual

offending group work

programme

Agreed Maps for Change is available to Offender Managers to inform work with those

who are not subject to an accredited sexual offending group work programme,

with changes due for release in early 2019. .

Training and provision of materials is underway for staff working with sex

offenders who are not subject to an accredited programme. This includes

specific face to face training for working with those who have committed

sexual offences commissioned by NPS (due to be available in late 2019),

which will support the delivery of such work, including the use of Maps for

Change. Regular communication, including through National Conferences, is

used to brief and update staff regarding new developments in working

effectively with those that have committed sexual offences.

In partnership with NHS England, the OPD pathway is available to support

work with people convicted of sexual offences, including those whose ability or

willingness to undertake accredited offending behaviour programmes is

impacted by Personality Disorder. Intensive Intervention and Risk

Management, will be introduced to support Community Offender Managers

(COMs) in engaging men and women screened into the OPD pathway and

provide tailored interventions during their licence and will be available across

most of England and Wales by the end of 2020. Therapeutic Communities are

accredited interventions available in custody and offer a more appropriate

treatment model than groupwork based Offending Behaviour Programmes in

some cases.

Within custody, the forum for Governors and other custodial staff groups in

relation to those convicted of sexual offences, includes a workstream to

consider further options for those for whom an accredited programme is not

the appropriate pathway, concluding in March 2020.

Deputy Director,

Effective Probation

Practice

Deputy Director,

Effective Probation

Practice

Head of

Psychological

Services and Head of

OPD Programme

Head of

Psychological

Services

April 2019

November 2019

December 2020

March 2020

12 Ensure that all convicted

sexual offenders in

custody have an allocated

NPS responsible officer

and prison-based offender

supervisor who is actively

Agreed All Registered Sexual Offenders will be assigned to NPS according to agreed

models. Once OMiC case management is implemented, a suitably trained

Prison Offender Manager (POM) will ensure effective coordination of the

sentence during the custodial stage of the sentence. A Senior Probation

Officer will be located in every prison, to oversee the management of sexual

Executive Director,

Safety and

Rehabilitation

December 2019

involved in managing the

case.

and violent offenders in custody. Active management of the case will transition

to a Community Offender Manager (COM) in readiness for release.

13 HM Prison Service

should ensure that:

Public protection

procedures, including the

monitoring of

communications, are

sufficiently robust and

consistently applied

Agreed HMPPS will review the guidance in the Public Protection Manual on how to

identify prisoners who pose a risk to children, to ensure it is clear, supports

public protection, ensures effective assurance through Interdepartmental Risk

Management meetings and is in line with legislation. All reviews of the need for

continued communications monitoring will be undertaken by suitably

competent staff, taking account of all relevant information about the prisoner.

An electronic learning package for staff involved in the interception of

communications will be launched.

Head of Public

Protection Group

September 2019

14 Prisons make a more

effective contribution in

their role as a MAPPA

responsible authority

Agreed The risk assessment and management element of the OASys training for

prison staff has been re-written to better equip prison staff to complete quality

assessments.

The national MAPPA Team will review the MAPPA Guidance. This will include

production of clear minimum requirements for single agency management.

This will also set out the framework for communication across the responsible

authorities, including prison contribution to MAPPA review meetings, and the

support to be provided by prisons for cases co-ordinated by a single lead

agency. HMPPS will consider an operational review of prison engagement, to

ensure compliance with formal processes.

The National MAPPA Team delivered presentations to the Regional Prison

Group Directors in November and December 2018 promoting the value of

ViSOR and the impact its use has in relation to MAPPA and protecting the

public. HMPPS has improved the process for providing staff with access to

ViSOR. To further support improved operational use of ViSOR across the

prison estate HMPPS has reviewed the current mandatory training.

Implementation of the updated training will begin by September 2019.

Head of Public

Protection Group

Head of Public

Protection Group

Head of Public

Protection Group

Completed

September 2019

Completed

15 All prisons have an active

strategy to reduce

reoffending, based on a

current needs analysis,

that sets out the steps to

be taken with the

Agreed The OMiC case management specification sets out the steps to be taken with

any group of prisoners. Prisons will actively adhere to this specification, taking

account of the framework for work with those convicted of sexual offences

(see recommendation one). HMPPS will work closely with Prison Group

Directors to assure effective implementation.

Director of Safety

and Rehabilitation

December 2019

population of convicted

sexual offenders.

National data will continue to be used to enable Prison Group Directors to

produce Offender Behaviour Programme delivery plans and strategies. The

Prison Estate Transformation Programme Model for Operational Delivery for

working with those convicted of sexual offences, will be considered by each

site holding relevant offenders to ensure approaches are in line with the

evidence, the population held, and wider HMPPS strategy.

Head of Analytical

Services Directorate

March 2020